Browne offered to sell Houlihan his recently purchased 50-inch plasma screen television set for $6,400. Houlihan sent Browne an e-mail accepting the offer but asked if she could pay Browne in four equal monthly installments of $1,600. Browne did not acknowledge Houlihan’s e-mail and instead sold the television set to Drew for $6,200. Houlihan then purchased a new set for

$7,400 and sued Browne for $1,000, the difference in price. Did Houlihan and Browne have a valid contract and will Houlihan be able to recover $1,000 from Browne?